Regulated facilities need to be sure their plans are in order because EPA is being more proactive with their SPCC inspections these days.
Each SPCC plan is unique to the facility it covers, but there are certain common elements must be included in each plan. Do you have them all?
Required Elements of the SPCC Plan
- A description of the physical layout and a facility diagram
- Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate federal, state, and local agencies that must be contacted in case of a discharge
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- Response Center, cleanup contractors, and all appropriate federal, state, and local agencies that must be contacted in case of a discharge
- A prediction of the direction, rate of flow, and total quantity of oil that could be discharged where experience indicates a potential for equipment failure
- A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters (For onshore facilities, one of the following must be used, at a minimum: dikes, berms, or retaining walls; curbing or drip pans; sumps and collection systems; culverting, gutters, or other drainage systems; weirs, booms, or other barriers; spill diversion ponds; retention ponds; sorbent materials.)
- Where appropriate, a demonstration that containment and/or diversionary structures or equipment are not practical; periodic integrity and leak-testing of bulk containers and associated valves and piping; oil spill contingency plan; and a written commitment of labor, equipment, and materials to quickly control and remove spilled oil
- A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations
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Proper SPCC Plan Formats
The “written’’ plan may include text, graphs, charts, maps, photos, and tables on whatever media (including floppy disk, CD, hard drive, and tape storage) allow the document to be easily accessed, comprehended, distributed, viewed, updated, and printed.
However, the plan must be readily accessible to response personnel in an emergency. If it is produced in a medium that is not readily accessible in an emergency, it must also be available in a medium that is. For example, a plan might be electronically produced, but computers fail and may not be operable in an emergency. For an electronic plan or plan produced in some other medium, therefore, a backup copy must be readily available on paper.
Also, at least one version of the plan should be written in English so that it will be readily understood by an EPA inspector.